Tax-settlement and refund escrow. Funds held by an independent trustee pending resolution.
A neutral escrow that holds funds through an ITA arrangement, or receives a tax refund into a segregated, documented account. Strict discipline: no third-party payments, ever. Money moves only per the arrangement, and the trust is run by a team that works with the ITA every day.
A neutral place to put the money while your counsel negotiates.
When a tax position is under negotiation with the ITA, the money cannot sit just anywhere. A neutral escrow with documented release conditions shows the ITA the amount is secured, and lets your tax counsel negotiate from a position of compliance rather than urgency. We hold; they negotiate; the arrangement decides.
Funds held neutral until the arrangement is finalized
ITA-facing documentation handled
Release follows the arrangement, not the parties
The refund trust
A documented home for a refund in motion.
Expecting a significant ITA refund from a deal, a withholding reclaim or a closed assessment? Every refund trust is its own uniquely numbered account, one client, never pooled, with you as the sole named beneficiary. The documentation set, a bank confirmation of the account plus the trustee’s certificate linking it uniquely to you, is built to what the ITA’s own guidelines define for a specific trust account.
A uniquely numbered account per client, never an omnibus pool
You are the sole named beneficiary, documented end to end
Released onward only at your instruction
ITA fluency, every day
We speak the ITA’s language because we work with it daily.
This is not a side product. ITA arrangements and refunds sit at the core of what we do across Section 102, restructuring and withholding. The same fluency applies to your arrangement escrow, and it is rare in the Israeli trustee market.
Daily working-level engagement with the ITA across services
Support for your advisors on the arrangement’s mechanics
Discipline enforced in writing at engagement
How it works
From review to release.
01
Tax structure reviewed.
We review the transaction and identify the ITA-related requirements: arrangements, certificates, escrow needs.
02
Filings prepared.
The ITA-facing documentation is prepared and tracked through to response.
03
Escrow established.
Where an ITA process is unresolved, a segregated escrow ring-fences the uncertain amount.
04
Resolution and release.
The arrangement concludes, the correct amounts flow per its terms, and the escrow releases on ITA resolution, fully documented.
FAQ
Common questions
Direct answers on tax-negotiation escrow and refund trusts.
A neutral, segregated trust that holds disputed or uncertain amounts while a tax position is negotiated with the Israel Tax Authority. The funds sit outside both parties’ reach, releases follow the documented arrangement only, and no third-party payment instructions are accepted from anyone.
Who usually engages the escrow?
The client’s tax counsel or accountant, as part of the negotiation strategy. We work alongside the advisor: they run the negotiation, we run the trust, and the documented arrangement governs every release.
What is a tax refund trust?
A segregated account that receives an ITA refund under a tax report, documents the onward flow, and keeps the funds ring-fenced until directed. Useful when the refund belongs to a structure rather than to one operating account.
I am a foreign resident owed an Israeli tax refund. Do I need an Israeli bank account?
Yes, the refund has to land in an account in Israel, and for many foreign residents opening a bank account just to receive a refund is nearly impossible. That is exactly what the refund trust solves: it gives you a uniquely numbered, segregated trust account in Israel, with you as the sole named beneficiary and documentation built to the ITA’s requirements. The refund is received there and transferred onward to your own account at your instruction, anywhere in the world. Especially relevant for refunds arising from tax-treaty reclaims.
Related trust services
Where tax meets the deal
M&A Paying Agent & Escrow
Withholding, ITA approvals and refunds handled in the same mandate.
